Expense & Procurement Policy

Introduction

PMG Consulting (hereafter referred to as PMG) is committed to the appropriate, transparent, and accountable use of organizational resources across all its global operations. This policy establishes the standards and approval procedures governing business expenditures, vendor selection, and procurement decisions to ensure financial integrity, operational consistency, and compliance with PMG's broader legal and ethical obligations.This policy operates within a single global framework. Where specific sections permit regional variation, this is indicated within the relevant section. All monetary thresholds in this policy are expressed in USD and must be converted to local currency at the prevailing exchange rate at the time of the transaction.

Scope

This policy applies to all PMG personnel as defined in the Intellectual Property Policy, including employees, contractors, consultants, embedded leaders, and executives, whether compensated by PMG or not. It applies to all expenditures incurred on PMG's behalf, whether project-related or internal, and to all procurement decisions involving external vendors, suppliers, subcontractors, or service providers.This policy should be read alongside the following PMG policies, each of which governs related areas of conduct:

• The Anti-Bribery & Corruption Policy, which governs gifts, hospitality, facilitation payments, and expenditures involving Public Officials;
• The Conflict of Interest & Client Segregation Policy, which governs procurement from vendors connected to PMG personnel or affiliated entities;
• The Whistleblower & Speak-Up Policy, which provides the reporting channel for concerns about expense fraud or procurement misconduct;
• The Document Retention & Destruction Policy, which governs the retention of expense and procurement records;
• The Political & Government Advisory Services Policy, which imposes heightened compliance obligations on expenditures arising in government engagement contexts.

Where this policy intersects with any of the above, both policies apply and the more restrictive standard prevails.

Definitions

Term	Definition
Business Expenditure:	Any cost incurred by PMG personnel on behalf of PMG, whether reimbursed directly or paid through PMG accounts, in connection with PMG's operations or client engagements.
Project Expense:	A business expenditure directly tied to a specific client engagement and eligible for reimbursement or client billing under the terms of that engagement.
Non-Project Expense:	A business expenditure that is not directly tied to a specific client engagement, including internal operational costs, firm-wide investments, and overhead expenditures.
Procurement:	The process of identifying, selecting, and engaging an external vendor, supplier, subcontractor, or service provider to supply goods or services to PMG.
Vendor:	Any external individual, company, or entity engaged by PMG to supply goods, services, software, or professional expertise.
Connected Vendor:	A vendor in which a PMG personnel member, or a person closely connected to them, holds a financial interest, directorship, employment relationship, or other material personal connection.
Value for Money:	An assessment of a procurement option based on the totality of cost, quality, reliability, and fit for purpose, rather than on price alone.
Competitive Quote Process:	The solicitation of a minimum of three independent written quotes from separate vendors for a procurement above the threshold defined in Section 4.2.
Finance:	PMG's finance function, administered via finance@askpmg.com, which holds sole authority over expense approval and payment.

1. Guiding Principles

1.1 PMG operates on the principle that consultants and personnel should not be expected to cover business costs out of their own pockets. PMG reimburses legitimate, pre-approved business expenses in full on a regular schedule. There is no default expense account or automatic spending allowance. Every expenditure must be justified, documented, and traceable to a legitimate business purpose.
1.2 All procurement decisions must be made on the basis of Value for Money. Cost alone is not a sufficient basis for vendor selection. Quality, reliability, fit for purpose, and alignment with PMG's operational and ethical standards are equally material considerations.
1.3 All expenditures and procurement decisions must be made free of any conflict of interest, consistent with the standards set out in the Conflict of Interest & Client Segregation Policy. Where a potential conflict exists, it must be disclosed and managed before any commitment is made.
1.4 No expenditure or procurement decision may be used, directly or indirectly, as a mechanism for bribery, corruption, or any improper advantage, consistent with the standards set out in the Anti-Bribery & Corruption Policy.

2. Expense Reporting and Reimbursement

2.1 The detailed process for submitting, documenting, and seeking reimbursement for business expenditures is governed by PMG's Expense Reporting & Approval Process (PM-414). All PMG personnel incurring business expenditures must follow that process in full. This section provides a high-level framework of the standards governing what may be submitted; PM-414 governs how.
2.2 All expense submissions must be supported by itemized receipts clearly showing the date of the expense, vendor name, itemized description of what was purchased, amount paid, and payment method. Receipts must match the data entered into the expense report exactly. Finance will not reconcile or interpret discrepancies.
2.3 Each expense must include a clear statement of business purpose. For project expenses, this must identify the relevant client and project. For non-project expenses, this must include pre-approval documentation as described in Section 3.
2.4 Finance holds sole authority over expense approval and payment. Individual managers have no authority to approve or reject expense reports. Manager pre-approval for non-project expenses authorizes submission only; Finance makes the final eligibility determination based on documentation provided.
2.5 Finance will action all expense reports within two weeks of submission. Accepted expenses will be added to the next scheduled pay cycle. Rejected expenses will be accompanied by an explanation, and eligible items within a partially rejected report may still be processed.
2.6 All monetary amounts must be entered in the currency in which the transaction occurred, using the applicable ISO currency code. USD thresholds referenced in this policy apply to all transactions regardless of the currency of the transaction, converted at the prevailing exchange rate on the date the expense was incurred.

3. Project and Non-Project Expenditures

Project Expenses

3.1 A project expense is eligible for reimbursement where it is directly and demonstrably tied to a specific client engagement. Eligible project expenses include travel for client site visits, client meals and entertainment with documented business purpose, software or tools purchased specifically for a project engagement, and materials or supplies required for project delivery.
3.2 Project expenses must be submitted in alignment with the relevant pay period's hours to ensure timely processing. Submissions made outside this cycle may be delayed to the next processing window.
3.3 The following expenses are not eligible for reimbursement as project expenses regardless of context: home office equipment or furniture, general productivity software not tied to a specific engagement, personal meals or commuting costs, and professional development or training not pre-approved in advance.

Non-Project Expenses

3.4 Non-project expenses are generally disallowed. Where a PMG personnel member believes a legitimate business expense does not fall within project categories, pre-approval must be obtained before the expense is incurred. Expenses submitted without pre-approval will be rejected without exception.
3.5 Pre-approval for non-project expenses must be requested from the personnel member's manager, who will assess the business purpose and necessity. Manager approval authorizes submission to Finance, which retains final approval authority.
3.6 Ongoing non-project expenditures that are not related to a client project, including operational investments, subscriptions, and firm-wide costs, must be submitted as a formal request or proposal to finance@askpmg.com for assessment and approval before any commitment is made to a vendor or supplier.

4. Vendor Selection and Procurement

4.1 All vendor selection decisions must be made on the basis of a Value for Money assessment. PMG personnel responsible for procurement must evaluate candidate vendors across cost, quality, reliability, relevant experience, and fit for the specific operational need. Price alone is not a sufficient basis for selection, and the lowest-cost option need not be selected where a higher-cost option demonstrably offers superior value across the assessment criteria.
4.2 Where the anticipated total value of a procurement engagement with a single vendor equals or exceeds USD $15,000 over a rolling twelve-month period, a Competitive Quote Process is mandatory. This threshold applies to the aggregate value of the vendor relationship across all transactions within that period, not to individual transactions in isolation. PMG personnel may not structure or split procurement arrangements into smaller tranches for the purpose of avoiding this threshold. A minimum of three independent written quotes must be obtained from separate vendors before any commitment is made. The quotes and the basis for the selection decision must be documented and retained in accordance with the Document Retention & Destruction Policy. Regional note: in jurisdictions where local procurement law imposes a stricter competitive process requirement, the local law standard applies.
4.3 Where it is not practicable to obtain three quotes for a procurement above the USD $15,000 threshold, for example where the required expertise is highly specialized or where only one or two qualified vendors exist in the relevant market, the procuring personnel member must document the reasons in writing and submit them to finance@askpmg.com for approval before proceeding. Finance may approve a sole-source or limited-source procurement on documented grounds of necessity.
4.4 All vendor engagements must be governed by a written agreement setting out the scope of services, deliverables, fees, payment terms, and termination rights at a minimum. No vendor may commence work on behalf of PMG without a signed agreement in place. Where the vendor will act on PMG's behalf in a client-facing or government-facing context, the agreement must additionally include the anti-bribery certification and contractual obligations required under the Anti-Bribery & Corruption Policy.

Connected Vendor Procurement

4.5 Procurement from a Connected Vendor is permitted subject to the following conditions:

1. The procuring personnel member must disclose the connection in writing to the Ethics Officer before any procurement process involving the Connected Vendor is initiated;
2. The Ethics Officer must provide written approval before any commitment is made to the Connected Vendor;
3. The procuring personnel member must recuse themselves from the vendor selection and assessment process. The selection must be conducted independently by another PMG personnel member with no connection to the vendor;
4. The Connected Vendor must participate in the Competitive Quote Process on the same terms as all other vendors, with no advantage conferred by reason of the connection;
5. All disclosures, approvals, and recusals must be documented and retained.

4.6 Failure to disclose a Connected Vendor relationship before procurement constitutes a violation of both this policy and the Conflict of Interest & Client Segregation Policy and will be treated as a serious breach.

5. Expenditure Categories: Specific Standards

Travel and Accommodation

5.1 Travel and accommodation expenses incurred in connection with client engagements are eligible project expenses where they meet the requirements of Section 3.1. All travel must have a clear and documented business purpose tied to a specific engagement or pre-approved internal requirement.
5.2 Unless circumstances prevent it, all travel must be arranged through PMG's travel function at travel@askpmg.com. Travel will book flights and accommodation on behalf of the consultant and provide itinerary and departure information in accordance with PMG's established travel procedures. Where travel is arranged by travel@askpmg.com, no further cost approval is required from Finance for the booking itself, as the travel function operates within PMG's established standards. Expense submission through PM-414 is still required for any incidental travel costs incurred by the consultant directly.
5.3 Where circumstances prevent travel from being arranged through travel@askpmg.com and a consultant must self-book, the following standards apply:

1. Air travel: Economy class is the default for all flights. Where the scheduled flight duration from departure to arrival as stated on the flight itinerary equals or exceeds six (6) hours, the consultant is eligible to book business class. First class is not reimbursable under any circumstances without the prior written approval of headsup@askpmg.com.
2. Accommodation: PMG does not impose a nightly cap on travel-arranged accommodation, as the travel function manages bookings directly within PMG's established standards. For self-booked accommodation in circumstances where travel@askpmg.com could not be used, the consultant must select accommodation that is fit for purpose and represents genuine value for money relative to the market and context. Finance will assess self-booked accommodation claims against the prevailing market rate for comparable accommodation in the relevant location at the time of booking. Claims materially above market rate will be subject to partial rejection, with reimbursement limited to the assessed market rate equivalent.
3. Ground transport: Reasonable ground transport costs including taxis, rideshares, and public transit are reimbursable where tied to a specific engagement. Car rentals require documentation of business necessity and must represent value for money relative to alternatives available in the market.
4. All self-booked travel must be submitted through PM-414 with itemized receipts and a clear statement of why travel@askpmg.com could not be used for the booking. Submissions that do not include this explanation may be rejected by Finance pending clarification.

5.4 Where travel involves interaction with Public Officials or government clients, the heightened standards set out in the Political & Government Advisory Services Policy and the Anti-Bribery & Corruption Policy apply in full, including the pre-approval requirements for any hospitality extended in that context.

Software and Technology Subscriptions

5.5 Software or technology tools purchased specifically for a client engagement are eligible project expenses where the purchase is approved by the engagement lead and documented with a clear project tie.
5.6 Software subscriptions or technology tools intended for general or firm-wide use are non-project expenditures and must follow the pre-approval process in Section 3.6 before any commitment is made. Personnel may not subscribe to or purchase software on PMG's behalf without pre-approval, regardless of cost.
5.7 Where a software or technology procurement equals or exceeds USD $15,000 annually, the Competitive Quote Process in Section 4.2 applies. Renewals of existing subscriptions above this threshold must be reviewed against the Value for Money standard at each renewal cycle and are not automatically exempt from the competitive process.
5.8 All software and technology vendors handling PMG or client data must meet the standards set out in PMG's Information Security Policy before engagement. Finance will not process payment to a software vendor that has not been cleared through that process.

Professional Services and Subcontractors

5.9 The engagement of external professional services providers and subcontractors, including independent consultants, legal advisors, researchers, and specialist practitioners, constitutes a procurement and is subject to all vendor selection standards in Section 4.
5.10 Where a subcontractor will be client-facing or will contribute to a client deliverable, the engagement lead must ensure the subcontractor is bound by confidentiality obligations and IP ownership terms consistent with PMG's Intellectual Property Policy before work commences.
5.11 Subcontractors engaged to act on PMG's behalf in any jurisdiction must provide the anti-bribery certification required under the Anti-Bribery & Corruption Policy before engagement. This is a non-negotiable precondition to any subcontractor engagement and Finance will not process payment to a subcontractor for whom this certification has not been obtained.

6. Records and Audit

6.1 All expense submissions, procurement decisions, vendor quotes, selection justifications, Connected Vendor disclosures, and pre-approval records must be retained in accordance with PMG's Document Retention & Destruction Policy. These records must be sufficient to allow Finance or Outside Counsel to reconstruct the basis for any expenditure or procurement decision at any time.
6.2 PMG reserves the right to audit any expenditure or procurement decision at any time. All PMG personnel must cooperate fully with any audit request and must provide access to supporting documentation upon request.
6.3 Finance will conduct periodic reviews of the gifts and hospitality register maintained under the Anti-Bribery & Corruption Policy to ensure consistency with expense submissions. Any discrepancy between a logged gift or hospitality item and a corresponding expense claim must be resolved before payment is processed.

7. Consequences of Violation

7.1 Any PMG personnel found to have violated this policy, including through submission of fraudulent expense claims, procurement decisions made in bad faith, failure to disclose a Connected Vendor relationship, or circumvention of the competitive quote process, shall be subject to the following consequences:

1. Immediate termination of employment or engagement for cause;
2. Recovery by PMG of all legal costs and expenses incurred in investigating the violation and enforcing its rights, subject to the due process requirements applied consistently across PMG's policies, meaning that cost recovery is triggered only following a formal written determination by Outside Counsel after notice and an opportunity to respond has been provided to the accused party, or following a finding by a court or regulatory authority;
3. Referral to law enforcement or relevant regulatory authorities where the conduct constitutes or may constitute a criminal offence under applicable law in any relevant jurisdiction.

7.2 Accidental errors in expense submissions are not treated as violations. Personnel who submit reports with errors will receive an explanation and may resubmit corrected items. Repeated procedural errors will result in mandatory training. Intentional or repeated misconduct will result in escalating consequences as described above.
7.3 Concerns about expense fraud or procurement misconduct may be reported through PMG's Whistleblower & Speak-Up Policy, which provides confidentiality protections and non-retaliation safeguards for reporters acting in good faith.

8. Policy Governance

8.1 This policy is administered by Finance in consultation with PMG's Outside Counsel. Questions regarding the interpretation or application of this policy should be directed to finance@askpmg.com.
8.2 The detailed operational process for expense submission, including template access, receipt upload requirements, and payment timelines, is governed by the Expense Reporting & Approval Process (PM-414). In the event of any inconsistency between this policy and PM-414 on a procedural matter, PM-414 prevails. In the event of any inconsistency on a standards or eligibility matter, this policy prevails.
8.3 PMG reserves the right to amend this policy at any time. Material amendments will be communicated to all PMG personnel and to active vendors and subcontractors where the amendment materially affects their obligations.